On September 15th I attended the DC public ‘roll-out’ of the report; “Sustainability and the U.S. EPA.” This report was requested by the U.S. EPA[1], to “… develop an operational framework for integrating sustainability as one of the key drivers within the regulatory responsibilities of EPA.”

The report was prepared by an ad hoc committee organized by, and for, the National Research Council under the National Academies’ Science and Technology for Sustainability Program (STS). This ‘COMMITTEE’ was appropriately called; “Committee on Incorporating Sustainability in the U.S. Environmental Protection Agency.” Their report makes the following important recommendations (along with four others not listed here):

1. The EPA should adopt and implement a comprehensive sustainability framework that includes specific work processes for incorporating sustainability into decisions and actions. [The process framework that was proposed by the committee is designed as a general work process that would be applicable to any type of decision that the EPA might need to make in the future. The latter two steps of the recommended framework are; “Sustainability Assessment and Management (SAM),” and “Periodic Evaluation and Public Reporting[2].”]

2. EPA should set several strategic 3-5 year breakthrough objectives related to its sustainability implementation and its performance indicators and associated metrics.

3. EPA should develop a “sustainability toolbox” that includes a suite of tools for use in the SAM approach. Collectively this suite of tools should have the ability to analyze present and future consequences of alternative decision options in terms of the full range of social, environmental, and economic considerations of well-being.

In the report there were numerous references pertaining to, or framed in terms of, a broad or macro-conceptualization of the word ‘sustainability[3].’ The summary (background) section of the report began by highlighting the fact that human well-being is very dependent on natural resources:

“Sustainability is based on a simple and long-recognized factual premise: Everything that humans require for their survival and well-being depends, directly or indirectly, on the natural environment. The environment provides the air we breathe, the water we drink and the food we eat. It defines in fundamental ways, the communities in which we live and is the source for renewable and non-renewable resources on which civilization depends.”

The COMMITTEE highlighted the importance of sustainability evaluation and its connection to policy development;

“Sustainability[4] is our true north. The work that we do – the research, the assessments, the policy development – is part of ensuring that we have a sustainable society, a sustainable civilization,”

and in the Sustainability Framework section of the report, it made reference to a number of very broad sustainability principles, including a citation from the “OECD Environmental Strategy for the First Decade of the Twenty-first Century:”

“Regeneration: Renewable resources shall be used efficiently and their use shall not be permitted to exceed their long-term rates of natural rates of natural regeneration.”

From the above framing, we have reason to be encouraged that the recommendations are meant to apply not only to local or regional decision making, but also to national level decision making and reporting.

The COMMITTEE was not charged with the task of recommending an implementation plan or time schedule. Implementation, both in scope and timing, is left up to EPA management. Consequently, and quite logically, in this report there is no mention of the need for an annual sustainability assessment for the nation as a whole, or the reporting of national assessment results. When I asked Paul Anastas (in a private conversation) if the EPA intended to apply the committee’s work process recommendations to future decision making at the national level, he indicated that his preference would be to apply the recommendations to essentially all decision making within EPA’s mandate; which includes informing national policy.

The COMMITTEE recommended, as part of their proposed framework for decision making, that the EPA develop a sustainability ‘vision’ and a set of criteria including sustainability objectives, goals, indicators, and metrics. The COMMITTEE’s recommendations also highlighted the need for “Stakeholder Engagement/Collaboration.” Therefore it would be most appropriate and timely, for the SWI, WWI, GFN, EPI, and other like-minded civil society stakeholders to contribute to the process dialog as EPA takes its “next-steps.” This would be a good time to press for SER at the national level.

The following people (among numerous others) were influential requesters of, and/or contributors to, the subject report:

Paul Anastas – Assistant Administrator for the Office of Research and Development (ORD) and Science Advisor to the EPA,

Alan Hecht – Director of Sustainable Development within the EPA’s ORD,

Bernard D. Goldstein, M.D. – University of Pittsburgh, Pennsylvania (chair of the COMMITTEE), and

Marina Moses, PhD – Director of the Science and Technology for Sustainability (STS) Program for the National Academies.

Suggestions for meeting follow-up:

This is a good time to be engaged with the EPA, as they begin to work on implementing some of the COMMITTEE’s recommendations. One of the next steps they have already taken is to commission a study about the best ways to ‘connect’ these sustainability recommendations with sustainable development activities within and among all other U.S. government agencies.

It will be appropriate to stay ‘connected’ with the EPA at this time, for the following reasons:

1. To participate in any future initiatives designed to obtain civil society feedback about the COMMITTEE’s recommendations

2. Continue to encourage the EPA to apply the COMMITTEE’s recommendations at a national spatial scale (National SER), and to highlight the importance of resource macro-balancing as a fundamental requirement of sustainability

3. Support EPA’s efforts to develop an appropriate national ‘sustainability vision’ and to suggest sound criteria and methodologies for evaluating future progress towards that vision

4. To understand and develop opportunities to obtain EPA grant money that may become available as a result of this over-all process to incorporate sustainability thinking into the agency.

It is very encouraging to witness these new sustainability initiatives within the EPA, and to interact with the internal network of EPA employees who are thinking about this important subject. However, this positive feeling must be somewhat tempered by the occurrence of recent congressional attacks on the EPA, that are designed to constrain their enforcement activities (supposedly in the interest of greater “economic opportunity”). Such attacks are, of course, short sighted. Their very existence in today’s political landscape should prompt a renewed commitment to educating the public (and policy makers) about the importance of protecting the nation’s foundational environmental assets. Human well-being, now and especially in the future, depends on preserving these natural resource assets in perpetuity.

EAB 9/27/11

[1] By an informal network of people within the EPA who view sustainability in a broader context than just ensuring air and water quality, and protecting human health.

2 It is good to that see one of the two major concepts that the SWI promotes [sustainability evaluation and reporting (SER)] as an integral part of the COMMITTEE’s recommendations.

3 The committee did not comment on the difference between strong and weak sustainability.

4 The conceptual interpretation of the word ‘sustainability’ was not debated by the committee. They accepted, as given, the meaning as defined in Executive Order 13514 as follows; “to create and maintain conditions under which humans and nature can exist in productive harmony, that permit fulfilling the social, economic, and other requirements of present and future generations.”